11/05/2007 291 Response Filed by Plasticon International, Inc. (RE: related document(s)101 Response filed by Debtor Plasticon International, Inc., 83 Motion for Relief From Stay filed by Creditor Pro Plas LLC). (Attachments: # 1 Continuation of Main Document Exhibit: Pro Mold Second Response to the Motion for Relief of Stay filed by the Murphy Entities) (Kennedy, Ellen) (Entered: 11/05/2007)
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Doc 291
IN RE:
PLASTICON INTERNATIONAL, INC.
Debtor.
Case No. 07-50934
Judge William S. Howard
Chapter 11
SECOND RESPONSE OF PLASTICON INTERNATIONAL, INC. TO MOTION FOR RELIEF FROM AUTOMATIC STAY FILED BY PRO PLAS, LLC
Plasticon International, Inc. (“Plasticon” or “Debtor”), through counsel, respectfully submits this Second Response to the Motion for Relief from Automatic Stay filed by Pro Plas, LLC [D.E. 83] filed herein on June 22, 2007. For its Second Response, Plasticon, Debtor, refers the Court to the following:
1. Response to Motion of Pro Plas, LLC (“Response”) filed herein on July 11, 2007, [D.E. 101] on behalf of the Debtor and Debtor-in-Possession.[1]
2. Second Response of Pro Mold to Motion for Relief from Automatic Stay filed by the Murphy Entities (“Second Response”), which Second Response was filed in the Chapter 11 case of Pro Mold, Inc., Case No. 07-50935, on September 25, 2007 [D.E. 214], a copy of which is attached hereto and incorporated herein as though set out at length herein and as though filed by Plasticon International, Inc. herein.[2]
[1] The Response [D.E. 101] was filed herein and signed by then counsel for Plasticon International, Inc. in the above-captioned Chapter 11 case of Plasticon International, Inc., but apparently inadvertently in the introductory paragraph thereof referred to the Debtor-in-Possession as Pro Mold, Inc., rather than the Debtor-in-Possession, Plasticon International, Inc. Thus, this Second Response incorporates the Response to Motion of Pro Plas, LLC [D.E. 101] to correct said introductory paragraph.
WHEREFORE, Plasticon International, Inc. requests that the Motion for Relief from Automatic Stay filed by Pro Plas, LLC by denied.
FOWLER MEASLE & BELL PLLC
/s/ Ellen Arvin Kennedy
Ellen Arvin Kennedy, Esq.
300 West Vine Street, Suite 600
Lexington, KY 40507-1660
(859) 252-6700
(859) 255-3735 fax
EAKennedy@FowlerLaw.com
ATTORNEYS FOR DEBTOR,
PLASTICON INTERNATIONAL, INC.
CERTIFICATE OF SERVICE
I hereby certify that the foregoing was served this the 5th day of November, 2007, electronically in accordance with the method established under this Court’s CM/ECF Administrative Procedures and Standing Order dated July 25, 2002 upon all parties in the electronic filing system in this case.
/s/ Ellen Arvin Kennedy
ATTORNEY FOR DEBTOR
[2] For the convenience of the Court, Exhibit A through Exhibit BB are not attached thereto and the Court is respectfully referred to said exhibits to the Second Response [D.E. 214] filed in Pro Mold, Inc., Chapter 11, Case No. 07-50935. |
